---
type: court_doc
id: "court_ctb_1930_0"
court: "CTB"
case_no: "22-50073"
doc_number: 1930
doc_type: "ORDER"
filed_date: "2023-06-22"
lang: "zh"
url: "https://mubeitech.com/court/court_ctb_1930_0"
json_url: "https://mubeitech.com/api/court/court_ctb_1930_0"
---
# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION | -------------------------------------------



> 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。

## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

| ------------------------------------------------------  |          | x           |                         |
|---------------------------------------------------------|----------|-------------|-------------------------|
| In re:                                                  |          | :<br>:      | Chapter 11              |
| HO WAN KWOK, et al.,1                                   |          | :<br>:<br>: | Case No. 22-50073 (JAM) |
|                                                         | Debtors. | :<br>:      | (Jointly Administered)  |
| ------------------------------------------------------x |          |             |                         |

## **TRUSTEE'S WITNESS AND EXHIBIT LISTS IN CONNECTION WITH JUNE 27, 2023 HEARING ON TRUSTEE'S MOTION, PURSUANT TO BANKRUPTCY CODE SECTIONS 105 AND 363, BANKRUPTCY RULES 2002, 6004(c), AND 9014, AND LOCAL RULES 6004-1 AND 6004-2, SEEKING ENTRY OF ORDER: (I) AUTHORIZING AND APPROVING SALE OF THE LADY MAY FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS, AND ENCUMBRANCES, (II) AUTHORIZING AND APPROVING PURCHASE AND SALE AGREEMENT, AND (III) GRANTING RELATED RELIEF**

Luc Despins, as the appointed Chapter 11 Trustee to the Debtor's estate (the "Trustee"),

by and through his undersigned counsel, provides the witness list attached hereto as **Exhibit A**

and exhibit list attached hereto as **Exhibit B** for the June 27, 2023 hearing (the "Hearing") on the

*Trustee's Motion, Pursuant to Bankruptcy Code Sections 105 and 363, Bankruptcy Rules 2002,*

*6004(C), and 9014, and Local Rules 6004-1 and 6004-2, Seeking Entry Of Order: (i)*

*Authorizing and Approving Sale of the Lady May Free and Clear Of Liens, Claims, Interests,*

*and Encumbrances, (ii) Authorizing and Approving Purchase and Sale Agreement, and (iii)*

*Granting Related Relief* [Docket No. 1858] (the "Lady May Sale Motion") before the Hon. Julia

<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

A. Manning, United States Bankruptcy Court for the District of Connecticut (Bridgeport),

Courtroom 123, 915 Lafayette Blvd., Bridgeport, CT.

The Trustee reserves the right to supplement or amend these lists. The Trustee further reserves the right to introduce or otherwise rely upon any exhibit offered by any other party. The Trustee further reserves the right to introduce additional exhibits for authentication, rebuttal or impeachment purposes.

Dated: June 22, 2023 LUC A. DESPINS, New York, New York CHAPTER 11 TRUSTEE

By: */s/ Nicholas A. Bassett*  Nicholas A. Bassett (admitted *pro hac vice*) Paul Hastings LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

*and*

Avram E. Luft (admitted *pro hac vice*) Douglass Barron (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com douglassbarron@paulhastings.com

*and*

Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com

*Counsel for the Chapter 11 Trustee*

Case 22-50073 Doc 1930 Filed 06/22/23 Entered 06/22/23 18:40:24 Page 3 of 5

## **EXHIBIT A: WITNESS LIST**

The Trustee designates the following individuals whom he presently anticipates may be called as witnesses at the Hearing:

- 1. Luc A. Despins, as Chapter 11 Trustee
- 2. Dirk Johnson (Edmiston and Company Limited)
- 3. Dexter White (Engineering Operations & Certification Services, LLC)
- 4. Other witnesses to the extent necessary for the authentication of documents;
- 5. Other witnesses for rebuttal purposes.

## **EXHIBIT B: EXHIBIT LIST**

| Exhibit | Description of Exhibit                                                                                                             |  |
|---------|------------------------------------------------------------------------------------------------------------------------------------|--|
| 1       | Yatco.com Listing for Lady May                                                                                                     |  |
| 2       | Yachtworld.com Listing for Lady May                                                                                                |  |
| 3       | Edmiston Website on Lady May                                                                                                       |  |
| 4       | Edmiston Email Marketing: Lady May – New CA for sale (April 28, 2023)                                                              |  |
| 5       | Edmiston Email Marketing: Lady May – Now in Newport, RI (May 18, 2023)                                                             |  |
| 6       | Edmiston Email Marketing: Lady May – Now enrolled in the FTZ in Newport,<br>RI, including May 30, 2023 bid deadline (May 24, 2023) |  |
| 7       | Edmiston Market Overview – Monthly Mailer                                                                                          |  |
| 8       | PR & Editorial – Boat International Online (May 4, 2023)                                                                           |  |
| 9       | Online Advertising – Boatinternational.com                                                                                         |  |
| 10      | Online Advertising – Superyachttimes.com                                                                                           |  |
| 11      | Social Media – Instagram                                                                                                           |  |
| 12      | Social Media – LinkedIn                                                                                                            |  |
| 13      | Sample Email to Initial Bidders and other interested parties (May 24 and 25,<br>2023)                                              |  |
| 14      | Edmiston Marketing Report on Lady May                                                                                              |  |
| 15      | Bidder A – Letter of Intent (received May 19, 2023)                                                                                |  |
| 16      | Bidder A – Bid (received May 30, 2023)                                                                                             |  |
| 17      | Bidder B – Letter of Intent (received May 19, 2023)                                                                                |  |
| 18      | Bidder B – Bid (received May 30, 2023)                                                                                             |  |
| 19      | Bidder C – Letter of Intent (received May 20, 2023)                                                                                |  |
| 20      | Bidder C – Bid (received Ma 30, 2023)                                                                                              |  |
| 21      | Bidder D – Letter of Intent (received May 9, 2023)                                                                                 |  |

| 22 | Bidder D – Email re Increased Offer (received May 22, 2023)                                                                        |
|----|------------------------------------------------------------------------------------------------------------------------------------|
| 23 | Bidder E – Purchase Agreement (received May 17, 2023)                                                                              |
| 24 | Bidder F – Bid (received May 30, 2023)                                                                                             |
| 25 | Bidder G – Bid (received May 30, 2023)                                                                                             |
| 26 | Declaration of Dirk Johnson in Support of Lady May Sale Motion, Exhibit C to<br>Lady May Sale Motion [Docket No. 1858]             |
| 27 | Purchase and Sale Agreement (including Addendum), dated as of May 30, 2023,<br>Exhibit B to Lady May Sale Motion [Docket No. 1858] |
| 28 | Second Addendum to Purchase and Sale Agreement, dated as of June 19, 2023,<br>Exhibit A to Supplement [Docket No. 1913]            |